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The Use of E-mail to Transmit Child Identifying Information

New York State Department of Health
New York Early Intervention System (NYEIS) Electronic Mailing List

The Use of E-mail to Transmit Child Identifying Information


Dear Colleague:

The purpose of this e-mail is to serve as a reminder that  New York State Department of Health  standards  must be followed to ensure that confidentiality is maintained when sending personally identifiable information via e-mail or e-mail attachments.  The use of email to transmit child identifying information is inherently unsecure and does not meet federally required FERPA regulations.  To ensure the confidentiality of children and families in the EIP, please do not  send personally identifiable information via email or email attachments in the future unless you are using password protection, encryption, firewalls, or some other equally appropriate security measure.  An exception to the use of encryption if e-mail is to be used to exchange personally identifiable information  would be if a parent signs a specific informed consent which clearly outlines the inherent dangers of using unencrypted e-mail.  The parent must be aware of, and consent to, the use of unencrypted e-mail and the consent form must clearly identify the dangers of e-mail communication. The parent must also be aware of the persons with whom e-mail communications are taking place (including their e-mail addresses), and be informed of the information which is being communicated via e-mail.

Child specific identifiable information includes a list of personal characteristics or other information that would make it possible to identify the child, the parent or other family members with reasonable certainty. In addition to obvious identifiers such as name, address, parent name, the combination of facts presented in the e-mail (e.g., initials, family composition, unique diagnosis, heritage, neighborhood, etc.) should not be able to identify a particular family or child.  We recommend, when it is necessary to send information about a child through e-mail, to utilize their NYEIS child reference number to identify the child.  Another option available for sending personal information about a child, is to use the secure file transfer via accessing your Health Commerce System (HCS) account.

You may refer to  the information provided in Memorandum 2003-1 Guidance on Early Intervention Program Records  available on the Bureau's webpage at: http://www.health.ny.gov/community/infants_children/early_intervention/memo03-1.htm

Article ID: 313, Created On: 2/22/2016, Modified: 2/22/2016

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